LILY ALLEN PRIVACY POLICY
Lily Allen takes your privacy seriously where we deal with your personal data. This means information that identifies you personally such as your name, contact details, order history, credit/debit card details, marketing preferences or data that can be linked with such information in order to identify you directly or indirectly (“Personal Information”). References to “we” “our” or “us” in this Privacy Policy are to the Lily Allen entities listed as Controllers in the “Controllers of your Personal Information” section below. This Privacy Policy describes our practices in connection with Personal Information that we collect from you in person and through certain of our owned or controlled websites, online stores, web properties (e.g., widgets and applications) and mobile applications (“Mobile Apps”) in each case, that link to this Privacy Policy (each, a “Platform” or collectively our “Platforms”). This Privacy Policy applies to the Lily Allen as a whole and where there are local variations or additions concerning how we use your Personal Information collected from your home country, these are set out clearly in the Country Specific Schedules section of this Privacy Policy. Please treat these schedules as a part of this Privacy Policy. If you are a California resident, please note that we have a separate California Privacy Policy which applies to the collection and use of your Personal Information along with this Privacy Policy and also addresses your privacy rights. Please see our California Privacy Policy. Please note that our Platforms are not directed to individuals under the age of sixteen (16), and we request that such individuals do not provide Personal Information through the Platforms.- CONTROLLERS OF YOUR PERSONAL INFORMATION
- HOW WE USE YOUR PERSONAL INFORMATION
| Information we collect | How we use your information and our lawful bases |
| User Account You give us Personal Information about you when you register for an online account on any of our Platforms (e.g. our e-commerce stores online). This is generally information including your name, and email address. When you complete your account information after registration and use your account, you give us additional information about you. This is generally Personal Information including your address details (shipping address and billing address), contents of your shopping cart, order history, preferred payment details (e.g. credit/debit card/PayPal) and marketing preferences. | Provide a requested service / carry out a contract with you
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| Purchases/Orders You give us Personal Information about you when you place an order on any of our Platforms. This is generally information including the contents of your shopping cart, your name, email address, telephone number, shipping address, delivery preferences and payment details (e.g. credit/debit card/PayPal) | Provide a requested service / carry out a contract with you To complete and fulfil your purchases on our Platforms, including processing your payments, sending you an order confirmation, sending you updates on your order and having your order delivered to you. To send you administrative information, including information regarding our Platforms and changes to our terms, conditions and policies. Comply with a legal obligation To comply with any relevant consumer laws in relation to purchases you make, including regarding giving you certain information and issuing replacements, credits or refunds (if applicable). |
| Purchases from Third Parties We collect Personal Information about you when you purchase any of our offerings from a third-party (e.g. when you make an album purchase on Ticketmaster). This is generally information including your name, telephone number, order details, shipping address and delivery preferences. | Provide a requested service / carry out a contract with you To complete and fulfil your purchases from our third-party partners, including sending you an order confirmation, sending you updates on your order and having your order delivered to you. |
| Customer Service Support You give us Personal Information about you when you contact us in relation to an order or support request you have made on any of our Platforms. This is generally information including your name, email address, payment details, order details (including shipping and delivery preferences) and details of your enquiry or query. | Provide a requested service / carry out a contract with you To communicate with you regarding purchases you have made on our Platforms and provide you with related customer service. |
| Information we collect | How we use your information |
| Competitions, Sweepstakes and Similar Promotions You give us Personal Information about you when you participate in any of our competitions, sweepstakes, or similar promotions. This is generally information including your name, gender, telephone number, email address, date of birth, post code, country, city, details of the competition or sweepstake you have participated in and your entry. Please bear in mind that the types of Personal Information collected above may vary (we may only request for you to provide some of the Personal Information above) depending on the promotion you agree to participate in. We will tell you what information is required prior to you entering any of our promotions. | With your consent To allow you to participate in our competitions, sweepstakes or similar promotions, and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Information. If there are any additional rules, these will be provided to you prior to your participation - please read these rules carefully before providing us with your Personal Information. |
Direct Marketing
You give us Personal Information about you when you sign up/agree to receive marketing communications from us.
This is generally information including your name, email address, telephone number and marketing preferences. Depending on the marketing campaign, this may also include your country, city, date of birth, and gender where you provide us with these additional details.
There are several ways you can sign up to receive marketing from us including:
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With your consent
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| Social Media Audience Advertising You give us Personal Information about you when you sign up or agree to receive marketing communications from us including social media advertising. This is generally information including your name, email address, social media username or handle, telephone number and marketing preferences. Where we have a social media pixel on any of our Platforms, you give us Personal Information about you when you consent to this pixel interacting with and collecting data from your device when you access our Platforms. This is generally information on the fact that you have visited our Platforms and have an account on our partner social media platforms (e.g. Facebook or Google). Please see our Cookies Policy for further information on social media pixels and how they work. You can find it at the bottom of our website pages, next to our Terms of Use. | With your consent
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| Information we collect | How we use your information |
| Digital Service Providers Direct Marketing We partner with digital service providers. If you have an account with a digital service provider ( e.g. Spotify) and agree to receive marketing communications from their partners through using their online tools, your digital service provider shares your Personal Information with us for this purpose. This information includes your name, date of birth, gender, email address and post code. | With your consent To send you themed marketing communications by email and in line with your marketing preferences. See also the “Listening Behaviour on Streaming Platforms” section below which discusses other ways we interact with streaming platforms to send you content that is relevant to you where you have consented to this. Please note that you can opt-out of receiving these communications at any time by selecting the unsubscribe link in any email we send, by emailing us at info@dreamteammusic.co.uk or by opting out through your digital service provider’s platform. |
| Entering Competitions, Sweepstakes and Similar Promotions with a Social Media Account. If you use your social media account (e.g. Facebook), streaming platform account (e.g. Spotify) or any other third party user account to enter our competition, sweepstakes or promotions or via an invitation to sign into such account on our Platforms, you will share certain Personal Information from your third party account with us which may include, for example, your name, gender, email address, city, country, listening history, favourite tracks, details of the promotion you have participated in, your entry and any other Personal Information that you make accessible to us. | With your consent To allow you to participate in our competitions, sweepstakes or similar promotions, and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Information - please read these rules carefully prior to providing us with your Personal Information. |
| Listening Behaviour on Streaming Platforms If you give us permission to, we collect Personal Information from streaming platforms you use (e.g. Spotify) on your listening behaviour on their platform. This includes information on tracks, playlists and albums listened to, along with your top genres and artists. | With your consent
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| Pre-save/Pre-add If you pre-save or pre-add any of our unreleased content on a streaming platform, the streaming platform may share your Personal Information with us. This may include information on the pre-save/pre-added content you have selected, along with your name, email address, city, country and (if applicable) your marketing preferences where you have opted into receiving marketing communications from us. | With your consent
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| Information we collect | How we use your information |
| General Enquiries You give us Personal Information about you when you contact us or otherwise interact with us generally, including via email, SMS, social media, online contact form, telephone call, SMS post or otherwise. This is generally information including your name, contact information, and details of your communication. | Necessary for our legitimate interests To respond to your inquiries and fulfil your requests, for example, when you send us questions, suggestions, compliments or complaints, or when you request information about our Platforms. We may also take such into account when improving our Platforms, products and services. |
| Surveys You give us Personal Information about you when you participate in and complete any of our surveys. This is generally information including your name, contact information, and your survey responses. | With your consent To register you for our surveys and to analyse the responses you have provided to our survey questions. |
| Information we collect | How we use your information |
| Email Deliverability We collect certain Personal Information by automated means when we send you marketing emails in line with your marketing preferences. This is generally information including whether you have opened the email and what you have clicked on within the email. Please see our Cookies Policy for information on what Cookies (and other similar technologies) are and how we use them. You can find it at the bottom of our website pages, next to our Terms of Use. | With your consent
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Accessing our online Platform
We collect certain Personal Information by automated means when you visit or interact with any of our online Platforms. This is generally information including:
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It is necessary for our legitimate interests
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| Cookies (and Similar Technologies) When you visit any of our online Platforms. we collect Personal Information about you through cookies and similar technologies placed on your device. The information collected may include a user ID assigned to you, your IP address, the content you have interacted with on our Platforms, duration of each visit to our Platforms, error messages encountered when using our Platforms and your interactions with social plug-ins (e.g. Facebook like or share button) on our Platforms. Please see our Cookies Policy for information on what Cookies (and other similar technologies) are and how we use them. You can find it at the bottom of our website pages, next to our Terms of Use. | Necessary for our legitimate interests
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| Information we collect | How we use your information |
| Aggregating Personal Information Our aggregating of Personal Information may apply to any of the above Personal Information we collect about you. | Necessary for our legitimate interests
To aggregate any Personal Information we collect so that in its final aggregated form, it will no longer directly identify you or any other individual. For example, by using Personal Information collected from website visits to calculate the percentage of our users who like a particular Artist. We use the aggregated data generated for multiple purposes including:
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| Audits (Internal and External) and Compliance Our audit and compliance process may apply to any of the above Personal Information we collect about you. | Necessary for our legitimate interests To verify that our internal processes function as intended. Necessary to comply with a legal obligation To verify that our internal processes are compliant with legal, regulatory or contractual requirements. |
| Fraud and Security Our fraud and security monitoring process may apply to any of the above Personal Information we collect about you. | Necessary for our legitimate interests To carry out fraud and security monitoring within our business, for example, to detect and prevent cyberattacks or attempts to commit identity theft. |
| Administration Our administrative processes may apply to any of the above Personal Information we collect about you. | Necessary for our legitimate interests To operate efficiently within our business model and corporate structure, in a way that effectively services our customers, including by using a range of centralised and localised business functions. |
| Legal claims Our legal claims process may apply to any of the above Personal Information we collect about you. | Necessary to comply with a legal obligation / Legitimate interests (depending on the situation) To effectively defend or bring claims to protect our legal rights and interests, and to respond to investigations from regulators or law enforcement. |
- We share your Personal Information with affiliates for the purposes described in this Privacy Policy.
- We share your Personal Information with companies who perform services on our behalf (and in some cases, our affiliates), to enable them to support the services we provide to you including those listed below. These can include consultants, providers of professional advisory services (such as lawyers and accountants), digital marketing agencies, service providers involved in hosting (cloud providers such as AWS and Microsoft Azure), marketing technology (such as for email campaign creation, email automation, managing opt-outs etc), data analysis (such as website traffic analytics), payment processing (such as PayPal), order fulfilment (such as shipping/delivery of customer orders), infrastructure provision (such as website and application development), auditing (external auditors such as KPMG and PWC), IT services, customer service, email delivery, credit card processing, and other similar services.
- We share your Personal Information with third parties (including our partners and artists) to permit them to send you marketing communications, consistent with your marketing preferences. For example, when you register to receive an artist’s newsletter.
- We share your Personal Information with our social media partners for the purposes of carrying out Social Media Audience Advertising and when we use social media plug-ins on our Platforms.
- We share your Personal Information with third parties that sponsor contests, sweepstakes and similar promotions so that they can offer and administer such contests, sweepstakes and promotions.
- Any Personal Information that you post or disclose on or through public areas of our Platforms (e.g. through message boards, chat, profile pages and blogs) will become public information, and may be available to visitors to our Platforms and to the general public, and may be redistributed through the Internet and other media channels where they will reach an even broader audience.
- We share your Personal Information if we are under a duty to do so, in order to comply with (and/or where we reasonably believe we are under a duty to comply with) any legal or regulatory obligation, such as pursuant to court orders, enforcement action from regulators or law enforcement; or in order to enforce any agreement we have in place with you; or to protect the rights, property, safety, or security of the Lily Allen brand, our affiliates, our artists, you, others third parties, users of our Platforms or the general public.
- We share your Personal Information in connection with a sale or business transaction. We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
- We share your Personal Information to enforce our terms and conditions or any other contracts we have with you and to allow us to pursue available remedies or limit the damages that we may sustain in any action, such as pursuant to court orders and engaging debt collection agencies.
- DO WE TRANSFER YOUR PERSONAL INFORMATION?
- HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
- The length of time we have an ongoing relationship with you and provide our Platforms to you (for example, for as long as you have an account with us or keep using the Platforms);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them);
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations); and
- Any guidelines issued by relevant legal and data protection authorities.
- SENSITIVE PERSONAL INFORMATION
- UPDATES TO THIS PRIVACY POLICY
- COUNTRY SPECIFIC SCHEDULES
| Rights | What does this mean? |
| The right to be informed | You have the right to be provided with clear, transparent and easily understandable information about how we use your Personal Information and your rights. This is why we are providing you with the information in this Privacy Policy. |
| The right of access | You have the right to obtain access to your Personal Information (if we are processing it), and certain other information (like the information provided in this Privacy Policy). This is so you are aware and can check that we are using your Personal Information in accordance with data protection law. |
| The right to rectification | You are entitled to have your Personal Information corrected if it is inaccurate or incomplete. |
| The right to erasure | This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your Personal Information where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions. |
| The right to restrict processing | You have rights to ‘block’ or suppress further use of your Personal Information. When processing is restricted, we can still store your Personal Information, but may not use it further. We keep lists of people who have asked for further use of their Personal Information to be ‘blocked’ to make sure the restriction is respected in future. |
| The right to data portability | You have the right to receive your Personal Information in a structured, commonly used and machine-readable format and to request that this data is transmitted to another controller where this is technically feasible. This right only applies to Personal Information you have provided to us yourself (not any other information), that we process by automated means based on your consent or for the performance of a contract with you. |
| The right to object | You have the right to object to the use of your Personal Information in some circumstances, such as where we don’t have to process your Personal Information to meet a contractual or other legal obligation. For example, you may object to the use of your Personal Information for direct marketing purposes. We can still store your Personal Information, but we can no longer use it in the way that you have asked us not to. |
| The right not to be subject to a decision based solely on automated processing, including profiling | You have the right not to have your Personal Information used to make solely automated decisions about you that you impact you. For example, you have the right not to have your Personal Information used to create a profile of you that automated decisions are later based on without there being any human involvement in that processing. |
| The right to lodge a complaint | You have the right to lodge a complaint about the way we handle or process your Personal Information with your relevant national data protection regulator. See details of the EEA data protection regulators here. |
| The right to withdraw consent | If you have given your consent to anything we do with your Personal Information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your Personal Information with your consent up to that point is unlawful). This includes the right to withdraw consent to us using your Personal Information for marketing purposes. |
| Rights | What does this mean? |
| The right to be informed | You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this Privacy Policy. |
| The right of access | You have the right to obtain access to your information (if we are processing it), and certain other information (like the information provided in this Privacy Policy). This is so you are aware and can check that we are using your information in accordance with data protection law. |
| The right to rectification | You are entitled to have your information corrected if it is inaccurate or incomplete. |
| The right to erasure | This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions. |
| The right to restrict processing | You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future. |
| The right to data portability | You have the right to receive your information in a structured, commonly used and machine-readable format and to request that this data is transmitted to another controller where this is technically feasible. This right only applies to information you have provided to us yourself (not any other information), that we process by automated means based on your consent or for the performance of a contract with you. |
| The right to object | You have the right to object to the use of your Personal Information in some circumstances, such as where we don’t have to process your Personal Information to meet a contractual or other legal obligation. For example, you may object to the use of your Personal Information for direct marketing purposes. We can still store your Personal Information, but we can no longer use it in the way that you have asked us not to. |
| The right not to be subject to a decision based solely on automated processing, including profiling | You have the right not to have your Personal Information used to make solely automated decisions about you that you impact you. For example, you have the right not to have your Personal Information used to create a profile of you that automated decisions are later based on without there being any human involvement in that processing. |
| The right to lodge a complaint | You have the right to lodge a complaint about the way we handle or process your information with the UK data protection regulator (ICO). Please see contact details for the ICO below: Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Phone number: 0303 123 1113. Website: https://ico.org.uk/make-a-complaint/ |
| The right to withdraw consent | If you have given your consent to anything we do with your information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your information with your consent up to that point is unlawful). This includes the right to withdraw consent to us using your information for marketing purposes. |
- CALIFORNIA PRIVACY POLICY
- Identifiers. such as name, contact information (address, email address, telephone number), an IP address that can reasonably be linked or associated with a particular consumer or household, Social Security number, social media username or handle, and online identifiers;
- Customer Records Information.Personal information as defined in the California customer records law, such as name, contact information, and financial account information;
- Protected Class Information.Characteristics of protected classifications under California or federal law, such as gender and age;
- Transaction Information. Commercial information, such as order history, contents of shopping cart, payment details, order delivery preferences, and listening history and preferences;
- Online Use Information. Internet or network activity information, such as browsing history, search history, and interactions with our online properties or ads;
- Geolocation Information. Geolocation information, such as device location and approximate location derived from IP address;
- Audio/Video Information. Audio, electronic, visual, and similar information, such as call and video recordings;
- Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
- AffiliatesWe share with our affiliates for the purposes described in this Privacy Policy.
- Service Providers. We share with our service providers, to facilitate the services they provide to us, such as website hosting, marketing services, data analysis, payment processing, order fulfilment, infrastructure provision, auditing, IT services, customer service, and email delivery.
- Business Partners. We share with third parties (including our partners and artists) to permit them to send you marketing communications, consistent with your marketing preferences.
- Ad Networks. We share with ad networks and online advertising partners to permit them to send you marketing communications.
- Social Media Platforms. We share with our social media partners for the purposes of carrying out Social Media Audience Advertising and when we use social media plug-ins on our Platforms.
- Promotion Sponsors. We share with third parties that sponsor contests, sweepstakes and similar promotions so that they can offer and administer such promotions.
- Legal Authorities. We share with public and government authorities, including regulators and law enforcement, to respond to requests, as well as to protect and defend legal rights.
- Other Parties in Legal Proceedings. We share Personal Information in the context of litigation discovery and in response to subpoenas and court orders.
| Categories of Personal Information | Disclosed to Which Categories of Third Parties for Operational Business Purposes | Sold to Which Categories of Third Parties |
| Identifiers | Affiliates; Service Providers; Business Partners; Promotion Sponsors; Ad Networks | Ad Networks |
| Customer Records Information | Affiliates; Service Providers; Business Partners; Promotion Sponsors; Ad Networks | Ad Networks |
| Protected Class Information | Affiliates; Service Providers; Ad Networks | Ad Networks |
| Transaction Information | Affiliates; Service Providers; Business Partners; Promotion Sponsors; Ad Networks | Ad Networks |
| Online Use Information | Affiliates; Service Providers; Ad Networks | Ad Networks |
| Geolocation Information | Affiliates; Service Providers; Promotion Sponsors; Ad Networks | Ad Networks |
| Audio/Video Information | Affiliates; Service Providers | None |
| Inferences | Affiliates; Service Providers; Ad Networks | Ad Networks |
- The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
- The specific pieces of Personal Information we collected about you;
- The business or commercial purpose for collecting or selling Personal Information about you;
- The categories of Personal Information about you that we sold and, for each, the categories of third parties to whom we sold such Personal Information; and
- The categories of Personal Information about you that we otherwise shared and, for each, the categories of third parties with whom we shared such Personal Information.
- Proof of your registration with the California Secretary of State to conduct business in California; and
- Proof that the consumer has authorized you to make a Request to Know or a Request to Delete on the consumer’s behalf. This must be a permission signed by the consumer. “Signed” means that the permission has either been physically signed or provided electronically in accordance with the Uniform Electronic Transactions Act, Civil Code 1633.7 et seq.
- Require the consumer to provide you with a written permission signed by the consumer to make the request on the consumer’s behalf;
- Verify the identity of the consumer as we would if the consumer were making the request personal; and
- Obtain verification from the consumer that they provided you permission to make the request.
- Proof of your registration with the California Secretary of State to conduct business in California; and
- Proof that the consumer has authorized you to make a Request to Know or a Request to Delete on the consumer’s behalf. This must be a permission signed by the consumer. “Signed” means that the permission has either been physically signed or provided electronically in accordance with the Uniform Electronic Transactions Act, Civil Code 1633.7 et seq.